Privacy Policy

EWF Martial Arts (“we”, “us” or “our”). Our address for correspondence is Unit 7, St Marys Business Park, Albany Road, Market Harborough, LE16 7QJ.

We take the privacy of our non-members / leads, website users and registered members very seriously and are committed to protecting your privacy when you use our services.

EWF Martial Arts has two lawful bases for processing personal data. Lead / Non-Members legal basis = Consent, and Registered Members legal basis = Contract

This Privacy Policy explains how we collect, process, use and store your personal information as a lead / non- member when you express interest and request service information via our website, by telephone, social media or in person.

This Privacy Policy explains how we collect, process, use, store and share your personal data as a registered member of EWF Martial Arts.

We ask that you read this Policy carefully as it contains important terms and conditions regarding the collection, processing, usage, storing and sharing of your personal information; some of which may constitute as personal data and sensitive data.

By using our website, requesting service information, trialling our service or registering for our service you agree to be bound by and comply with this Policy.

If you do not agree with or accept this Policy you should not submit any personal information to us. We may update this Policy through time in accordance with the “Policy Updates” section below.

Data Protection

References in this Policy to:

“Data Protection Law” means: the Data Protection Act 1998 (until repealed) (“DPA”), the Data Protection Directive (95/46/EC) (until repealed) and, from 25 May 2018, the General Data Protection Regulation 2016/679 (“GDPR”) or any equivalent provision which may replace the GDPR following the formal political separation of the United Kingdom from the European Union; the Regulation of Investigatory Powers Act 2000; the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699); the Electronic Communications Data Protection Directive (2002/58/EC); the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and all applicable laws and regulations which may be in force from time to time relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction; and

“Personal Data”, “Data Controller”, “Data Processor” and “processing” shall have the meanings given to them in the DPA or, from 25 May 2018, the GDPR. ?For the purpose of applicable Data Protection Law, EWF Martial Arts are a Data Controller and therefore we are responsible for the control and the processing of your Personal Data in accordance with applicable Data Protection Law. Personal Data has a legal definition but in brief, it refers to the information from which a living person can be identified. Such information must be protected in accordance with Data Protection Law.

Information We Collect About You

We will collect specific personal information about you when you express interest and request service information through our website, by telephone or in person; we will only collect and use person information we need to deliver a service or meet a requirement you request. We will not sell your personal information to anyone else.

Electronic Website Data Collection: your personal information submitted is sub processed by ‘Aweber’; our website contact form engine. ‘Aweber’ transfers prospects submitted data to us via email. Prospects data is automatically stored within the Aweber online data base post submission which we erase following the receipt of the data by email. Data collected by Aweber is securely stored in their online data base using password protection.

Personal information collected may include (but is not limited to):

Full Name
Contact Number(s)
Contact Email Address
Date of Birth and Age
Physical Address & Postcode
Gender
Intentions and Interests
Physical / Mental Health Condition(s) Data
Nationality
Billing Account Details
Dependant Details (only where applicable)

Some of the above data may constitute as sensitive data including:

Physical / Mental Health Condition(s) Data
Nationality

Lead / Non-Members

As a lead / non-member you will be required to indicate your consent for the collection, processing, usage and storing of your personal information prior to submitting any data to us.

We require your personal information for the purposes of:

Lead / Non-Member Identification
Age Verification
Contact Number and Email; we will contact you by telephone to deliver service information on your ?interest(s) expressed and provide a free introductory trial appointment for you to taster our service
Understanding your intentions and interests
Medical Awareness; this will allow us to provide the safest and most suitable service to you

Registered Members

As a registered member of EWF Martial Arts we process your information for the purposes of:

Membership Contract registration and international recognition of your personal student profile
Billing; to automatically collect and monitor monthly membership fees (Direct Debit)
Communication; to keep members up to date with relevant service information, events / seminar schedules and details and ongoing courtesy contact to ensure we are providing the best possible service

We may monitor your use of the website and social media (Facebook advertising and campaigns) through the use of cookies. We may also monitor traffic, location and other information and data about visitors to the website and Facebook for management purposes. Information about your computer hardware and software also may be automatically collected. This information can include your IP address, browser type, domain names, access times and referring website addresses. This information is used by EWF Martial Arts for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of our website. Some of this data will be aggregated or statistical therefore it will not identify you individually.

Safety Of Children (Under 18)

We do not knowingly collect personal data from any persons under the age of 18 or allow them to request further information, book introductory trial appointments or register as a member without legal parent or guardian consent. If it comes to our attention that we have inadvertently collected personal information from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact info@ewfma.com

We will collect and process personal information for under 18s with the consent of their legal parent or guardian for membership registration purposes. Legal parent / guardian consent is given to us for the collection and processing of information by their signing of the membership contract.

Why We Use Your Information

We will only use your personal information for reasons known to yourself and outlined in this Privacy Policy. We will use your personal information for the following purposes:

To identify you as a lead / non-member or registered member
For age verification
Communication to leads / non-members: to provide service information following your interest(s) expressed
Communication to leads / non-members: we will contact you to offer a free introductory appointment for you to trial our service
Communication to leads / non-members: to confirm introductory trial appointments and to contact you to offer an earlier appointment should one become available following a cancellation
Management and Administration of your personal profile: to log attendance, activities and transactions
Members: to create your personal student profile and register you on to our international martial arts ?data base
Members: to update and promote your belt rank following a testing
Members: service usage and attendance details
Billing: to enter a membership contract and set up a monthly direct debit for membership fee collection and monitoring
Communication: to contact members for service and site updates / information, testing schedules and details and event / seminar schedules and details
Communication: to ensure ongoing courtesy contact is made with registered members for general feedback to ensure we are continuously providing the best possible and most suitable service to you
To ensure the terms and conditions of the membership contract are adhered to
To deliver services and support to you
To carry out any contractual obligations entered in to between us and you
Service improvement
Prevention / detection of crime / fraud

We will not require the consent of registered members to communicate with you by email or telephone (calls or texts) because we have assessed that it forms part of our agreement with you and it is of mutual interest for us to keep you informed and gain your feedback relevant to your contract with us.

How Long We Keep Your Information

Leads / Non-Members, we will securely store your personal information indefinitely / for as long as required in order to provide you with service information requested and to offer a free introductory appointment for you to trial our service relevant to your expressed interest(s).

Registered Members, we will securely store your information for as long as required to deliver and communicate our service to you in accordance with the membership contract agreement.

Lead / Non-Members

We require your consent to process your personal information for the purposes of communicating service information and trial appointments to you following your request & interest expressed.

You have the right to withdraw consent and request erasure of your personal information at any time by emailing: info@ewfma.com

Please provide relevant information for us to identify you to complete your request.

Please note, we will not be able to communicate service information and trial appointment availability to you if you withdraw your consent.

Registered Members

When registering as a member with EWF Martial Arts you will enter a membership contract agreement with us. We will store your information for as long as required to deliver and communicate all relevant service & contractual obligations / requirements.

You can request the termination of your membership contract in writing at any time by: Emailing info@ewfma.com

In accordance with the contracts ‘Terms of Membership’ and our ‘Membership Contract Cancellation Policy’ to cancel your contract you must do so in writing and pay the final full month’s membership fee; you will be eligible to train for the month.

If you do not comply with the cancellation process, we may continue to process your personal information until the cancellation process has been successfully completed.

Reasons that would entitle us to continue processing your personal information:

Breach of contract; either by not notifying us in writing and / or not paying the final outstanding full months membership fee
Student request to temporarily freeze their membership; this is to be authorised by the General Manager
Consent is obtained to continue communicating with former students as indicated on a ‘Membership Cancellation Confirmation Letter’; in accordance with our ‘Membership Contract Cancellation Policy’

When requesting membership contract cancellation, you will have the option for us to continue processing your personal information for the sole purpose of communicating service updates and information including upcoming events and seminars which may interest you. This is optional and will require you to physically opt in or deny the continued processing of your personal information; if you provide consent evidence will be stored as proof and attached to your personal profile. If you deny consent, all personal information stored will be erased following your final eligible training day.

Sharing Your Personal Information & Data

EWF Martial Arts only shares specific personal information of yours with sub-processors that are required in order to complete your membership contracts registration and help deliver our service to you.

There is one affiliate organisation we share specific information of yours with:

Educational Funding Company (EFC).

EFC is a billing collection company for the martial arts industry based in the UK. In order to instate your membership contracts monthly direct debit, specific personal information of yours is shared with EFC including:

Full Name
Date of Birth and Age
Contact Number
Contact Email Address
Physical Address and Postcode
Your Interests and our Service provided
Account Information
Purposes of sharing your personal information with EFC:
For the establishment of your membership contract and direct debit
For monthly membership fee collection
To monitor activities of collection
To follow up on any outstanding payments
To contact you regarding payments if required

The sub processors store your information and help deliver our service to you. Where we have these arrangements, there is an agreement in place to make sure that the organisation complies with data protection law. Sub processors are obliged to make reasonable efforts to safeguard your personal information stored. ?We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Site. In such circumstances we do not disclose any information which can identify you personally.

Legal Basis For Processing Your Information

Our lawful bases for processing differ dependant on whether you are a lead / non-member or a registered member of EWF Martial Arts. Our lawful base for collecting and processing lead / non-member personal information is consent. Our lawful base for collecting and processing registered members personal information is with a contract. As of May 25th 2018, under applicable Data Protection Law we may only process your information if we have a lawful base for doing so (a legally permitted reason).

For the purpose of this Policy, our legal bases for processing your information is:

Your consent (for Leads / Non-Members)
A contract agreement (for registered Members)

Consent

As noted above, you will be required to provide consent for the collection and processing of your personal information for the purposes outlined in this Privacy Policy. We will seek this consent prior to you submitting any personal information to us through our website, by telephone or in person. If you do not consent to such processing, you should not submit any information to us in any form. Purposes for collecting and processing your personal information include:

Lead / Non-Member Identification
Age Verification
To understand your intentions and interests
To communicate service information
To communicate appointment opportunities to trial our service free or charge
To ensure our service is safe and suitable for you to trial

If you withdraw your consent and we do not have another legal basis for processing your information we will stop processing your information and erase it.

Please note, we need to process your information to communicate service information and trial appointment opportunities to you. If you do not provide or withdraw consent, we will not be able to provide service information and trial appointments to you.

Contract

Registration for our service is agreed by contract. You will be required to carefully read the contracts terms and conditions so contractual and legal obligations are clear and understood. During this process, the General Manager will be present and available to explain, elaborate and clarify any elements of the contract agreement you wish to question or query.

If you proceed with membership registration and a contract is established multiple copies will be created:

For yourself as the member
For us as the service provider (we will securely store this online using password protection)
For EFC to instate your membership and direct debit (securely stored online using password protection)

Purposes for collecting and processing your personal information by contract include:

Registration of your personal student profile with us.
For the establishment of the membership contract and direct debit
To communicate with you regarding service updates and information
To communicate in-house testings, events and seminar schedules / details
To communicate customer courtesy and care to gain feedback and ensure we are providing the best possible service
For belt rank recognition and promotions

Keeping Your Information Secure

We will use technical and organisational measures in accordance with good industry practice to safeguard your Information. We collect your personal information online using a secure server and socket; HTTPS. Our online website is protected using anti-virus and internet security software. Our computer systems which store your personal information are password protected.

Only specific and required staff individuals will be able to access and use your information for the purposes sated in this Policy.

However, while we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.

Examples of security include:

Encryption: Information is hidden and cannot be accessed without special knowledge (password protected)
Online anti-virus and internet security software active
Controlling Access: by controlling access we stop people not permitted to view your information from ?gaining access
Staff Training: Staff are trained on how to handle and how / when to report any issues
Paper Copies: stored in locked areas; only required personnel have access

Monitoring

We may monitor and record communications with you (such as telephone conversations, texts and emails) for the purpose of quality assurance, training, fraud prevention and compliance. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for the purposes listed above.

Information About Other Individuals

If your give us information on behalf of a third party you confirm that the third party has appointed you to act on his / her / their behalf and has agreed that you can:

Give consent on his / her / their behalf to the processing of his/ her / their information
Receive on his / her / their behalf any data protection notices
Give consent to the sharing of his / her / their behalf (if applicable)

Your Rights

If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and /or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details below) giving us enough information to identify you and respond to your request.

You have the right (which up until 25 May 2018 may be subject to the payment of a small fee) to request information about Personal Data that we may hold and /or process about you, including: whether or not we are holding and /or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.

You have the right to have any inaccurate information we hold about you be corrected and /or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information deal with the change or correction.

You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case we will let you know.

You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see below).

You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you we will let you know.

You have the right in certain circumstances to object to processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests.
You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you we will let you know.

Processes To Exercise Your Rights With Us

Request to update or change information you think is inaccurate

Please let us know if you would like to update any of your personal information we store on site or you believe we have recorded inaccurate information about yourself. We may not always be able to change or remove that information but we will correct factual inaccuracies and will include your comments on your personal student profile. ?To request personal information updates or inaccurate information changes please: Email: info@ewfma.com

Alternatively, you can speak to our Receptionist when visiting us.

Request to delete your information (right to erasure)

In some circumstances you can request for your personal information to be deleted, including:

Your personal information is no longer needed for the initial purpose of collection
You have removed your consent for us to process your personal information (providing we have no other legal reason to process it)
There is no lawful base for us to process your personal information
Deleting your personal information is a legal requirement ?We will follow up with sub processing organisations to comply with your request of erasure.
Please note in some circumstances we may not be able to erase your personal information immediately, including:

To continue processing your personal information in accordance with our membership contracts terms and conditions
We are required to have it by law
It is necessary for legal claims

To request personal information erasure please Email: info@ewfma.com

Request to limit the personal information we process about you

You have the right to restrict the personal information we process about you if:

You have identified inaccurate personal information and notified us of it
We have no legal reason to process your personal information but instead of requesting erasure, you restrict your information

Upon receiving your request, we will assess whether you have the right to a restriction. We will inform you of the outcome.

We will seek to comply with your request where possible, but we may be required to continue the processing of your personal information if required by law or we have a legal base for doing so; a contract.

To request personal information limitation please: Email: info@ewfma.com

Request to have your personal data transferred to another provider

You have the right of data portability, where you may request for your personal information to be given back or transferred to another service provider. However, this only applies if we are processing your personal information on the base of consent, not if we are processing your information on the legal base of a contract. It is likely that data portability will not apply to the service you receive from the EWF Martial Arts.

Policy Updates

We keep this Policy under regular review and may update or make changes through time. If we change this Policy we will post the changes on this page and place notices on other pages of the website, our Facebook social media page and alert members via email.

Accessibility

This Policy aims to provide you with all relevant details about how and why we collect, process, use, store and share your information in a clear and simple language. If you have any difficulty reading or understanding this Policy or if you wish to discuss any elements of this Policy, please contact info@ewfma.com

Independent Advice

If you have any concerns about how we collect or process your Information then you have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (‘ICO’). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.

Contact

Calling: 07931 722910
Emailing us at: info@ewfma.com
Writing to us at: EWF Martial Arts, Unit 7, St Marys Business Park, Albany Road, Market Harborough, Leicestershire, LE16 7QJ